Reserved Alternative Investment Fund (RAIF)

The RAIF was introduced by the Luxembourg law of 23 July 2016. It can take several legal forms — including an investment company with variable or fixed capital (SICAV/SICAF), a common fund (FCP), or a partnership such as an SCSp — and can be set up as an umbrella with segregated compartments. Because it is not subject to product approval by the CSSF, it can be launched quickly, but it must appoint an authorized alternative investment fund manager (AIFM), which provides the regulatory oversight and the AIFMD marketing passport for professional investors in the EU.

RAIFs are reserved for well-informed investors: institutional investors, professional investors, and other investors who confirm in writing that they qualify and either invest at least €100,000 (lowered from €125,000 by a 2023 amendment) or obtain a qualifying assessment from a credit institution, investment firm or management company. A RAIF must appoint a Luxembourg depositary and an approved statutory auditor, and is registered with the Luxembourg Trade and Companies Register.

RAIFs are generally subject to an annual subscription tax of 0.01% of net assets, with exemptions, or can opt for a regime similar to the SICAR for risk-capital investments. Operationally they follow full AIFMD reporting, including Annex IV. Confirm current rules with Luxembourg counsel.